Case law

Estate of Vose v. Commissioner

14 T.C. 113 · United States Tax Court · Jan 30, 1950

In Commissioner v. Estate of Church, 335 U. S. 632 , and Estate of Spiegel v. Commissioner, 335 U. … See John Wanamaker Philadelphia v. Commissioner, 139 Fed. (2d) 644, 646; United States v. Title Guarantee & Trust Co., 133 Fed. (2d) 990; and Brown Rogers-Dixon Co. v.

Mitchell v. Commissioner

65 T.C. 1099 · United States Tax Court · Mar 4, 1976

Brown , 52 T.C. 50 , 59-60 (1969) . Additionally, the documents themselves are ambiguous on the issue of whether the option was compensatory. … The Court stated in Commissioner v.

Quality Auditing Co. v. Commissioner

114 T.C. 498 · United States Tax Court · Jun 19, 2000

As an organization exempt from taxation under section 501(c)(6), AISC is a business league or board of trade. … It is an organization of the same general class as a chamber of commerce or board of trade.

Estate of Paxton v. Commissioner

86 T.C. 785 · United States Tax Court · Apr 28, 1986

Bank v. … Allard v. La Plain, 152 Wash. 211 , 277 P. 843 (1929); Van Stewart v. Townsend, 176 Wash. 311 , 28 P.2d 999 (1934); Carroll v. Carroll, 18 Wash.2d 171 , 138 P.2d 653 (1943); Jones v.

Yale Ave. Corp. v. Commissioner

58 T.C. 1062 · United States Tax Court · Sep 28, 1972

Warehouse Co. v. … We note that It ivas held in Bradford v.

Sidney v. Commissioner

30 T.C. 1155 · United States Tax Court · Aug 25, 1958

On this date the board of directors of this corporation voted to increase the capital surplus of the corporation by the sum of $540,372.15, representing the difference between the original F. H. … Since the Court of Appeals for the Second Circuit has recently indicated in Glickman v. Commissioner, 256 F. 2d 108 , its concurrence in the opinion of the Court of Appeals for the Fourth Circuit in Burge v.

Help Children, Inc. v. Commissioner

28 T.C. 1128 · United States Tax Court · Aug 30, 1957

The remaining contributions were made to the f ollowing institutions: [[Image here]] The corporation is governed by a nonpaid board of trustees who are elected by the membership. … Eaton Foundation v. Commissioner, 219 F. 2d 527 , affirming Memorandum Opinion of this Court; cf. United States v. Community Services, Inc., 189 F. 2d 421 , certiorari denied 342 U. S. 932 .

Standard Oil Co. v. Commissioner

7 T.C. 1310 · United States Tax Court · Dec 10, 1946

Cohan v. Commissioner (C. C. A.) 39 F. (2d) 540 ; Island Petroleum Co. v. Commissioner (C. C. … Island Petroleum Co. v. Commissioner, supra . Cf. A. Giurlani & Bro., Inc. v.

Field v. Commissioner

32 T.C. 187 · United States Tax Court · Apr 24, 1959

See also Lucas v. Hunt, 45 F. 2d 781 ; United States v. City of New York, 134 F. Supp. 374 ; and Estate of Umberto Dardi v. United States, 252 F. 2d 670 . … United States v. Krueger, 121 F. 2d 842 , certiorari denied 314 U.S. 677 ; McPherson v. Commissioner, 54 F. 2d 751, 753 ; Helvering v. South Penn Oil Co., 68 F. 2d 420 ; Commissioner v.

Stout v. Commissioner

71 T.C. 441 · United States Tax Court · Dec 27, 1978

Walsh v. United States, 322 F.Supp. 613, 619 (E.D.N.Y. 1970). In this case, the petitioner was not absent from work on account of personal injury or sickness. … See O’Neal v. United States, 314 F.Supp 383 (D.S.C. 1969). Respondent correctly disallowed the sick pay exclusion.

Clifton Mfg. Co. v. Commissioner

1 T.C. 71 · United States Tax Court · Nov 18, 1942

As the Board said in Jamaica Water Supply Co., 42 B. T. A. 359, affd. (C. C. … See, e. g., Fisher v. Commissioner (C. C. A., 2d Cir.), 59 Fed. (2d) 192; Arthur L. Lougee, 26 B. T. A. 23, 26; affd. (C. C. A., 1st Cir.), 63 Fed. (2d) 112; Willkie v. Commissioner (C. C.

Wilson v. Commissioner

46 T.C. 334 · United States Tax Court · Jun 13, 1966

See Minnesota Tea Co. v. Helvering, 302 U.S. 609 (1938). … See, e.g., Becher v.

Estate of Miller v. Commissioner

18 T.C.M. 1127 · United States Tax Court · Dec 14, 1959

Pease, Co-Executrices v. Commissioner. Estate of M. Lucile Murton, Deceased, The United States National Bank of Portland (Oregon), Executor v. Commissioner. Estate of Miller v. Commissioner Docket Nos. 65411, 70564. … Murton and 35 700.00 other stockholders of the Company August 1954 Brown E. Sisson Est. Company 60 700.00 October 1954 Mrs. B. E. Sisson Fred Lund 5 700.00 267 (February 22, 1955 - Date of death of M.

Prosperity Co. v. Commissioner

17 T.C. 171 · United States Tax Court · Aug 6, 1951

Applying Cohan v. … Applying the doctrine of Cohan v.

Whistleblower 14106-10W v. Commissioner

76 A.L.R. Fed. 2d 713 · United States Tax Court · Dec 8, 2011

Cir. 1992) (upholding determination by Merit Systems Protection Board that employee was threatened with removal and unsatisfactory performance because disclosure of questionable employment practices); United States Merit … Litig., 732 F.2d 1302 , 1308 (7th Cir. 1984); Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165, 1178-1179 (6th Cir. 1983).

Lucas v. Commissioner

79 T.C. 1 · United States Tax Court · Jul 6, 1982

Commissioner v. Tellier, 383 U.S. 687, 689 (1966); United States v. Gilmore, 372 U.S. 39, 49 (1963); Ostrom v. Commissioner, 77 T.C. 608, 613 (1981). In Boagni v. … Accord Brown v. United States, 526 F.2d 135 (6th Cir. 1975). Petitioners presented little information regarding the nature of the suit against Roy.

Estate of Shafer v. Commissioner

80 T.C. 1145 · United States Tax Court · Jun 28, 1983

None of the opinions of the Board of Tax Appeals cited by petitioner bears upon the use of such documents as admissions of a party. In West Town State Bank v. … Bank v.

Pullman, Inc. v. Commissioner

8 T.C. 292 · United States Tax Court · Feb 12, 1947

See Commissioner v. Bedford's Estate , 325 U.S. 283 ; A. J. Long, Jr ., 5 T. C. 327 ; affd., 155 Fed. (2d) 847 ; Kirschenbaum v. Commissioner , 155 Fed. (2d) 23 ; Bazley v. Commissioner , 155 Fed. (2d) 237 . … See also Flanagan v.

Lurie v. Commissioner

4 T.C. 1065 · United States Tax Court · Mar 31, 1945

In the Werner case the Board of Tax Appeals held that gain realized when certain bonds were retired and called prior to maturity was a gain on the “sale or exchange” of a capital asset within the meaning of section 206 of … See Fairbanks v. United States, 306 U. S. 436 .

Horne v. Commissioner

5 T.C. 250 · United States Tax Court · Jun 15, 1945

Tax laws deal with realities (Helvering v. Security Savings & Commercial Bank, 72 F. (2d) 874 (C. C. A. 4) ; MacQueen & Co. v. Comm., 67 F. (2d) 857 (C. C. … A. 3)), and look at the entire transaction (cases just cited and Ahles Realty Corp. v. Comm., 71 F. (2d) 150 (C. C. A. 2)). Two very recent cases (Commissioner v. Dyer, 74 F. (2d) 685, and Marston v.